STATE BANK OF PATIALA vs. COMMISSIONER OF INCOME TAX, PATIALA

IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH ****

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ITA-200-2012 Date of Decision: 19.12.2025 STATE BANK OF PATIALA, PATIALA ...Appellant Vs. COMMISSION OF INCOME TAX, PATIALA

…Respondent

CORAM:- HON'BLE MR. JUSTICE JAGMOHAN BANSAL HON'BLE MR. JUSTICE AMARINDER SINGH GREWAL

Present:- Mr. Sanjay Bansal, Sr. Advocate with Mr. Gurdeep Singh, Advocate Mr. Sushrut Singla, Advocate and Mr. Iman Singla, Advocate for appellant-State Bank of Patiala

Mr. Saurabh Kapoor, Sr. Standing Counsel (through V.C.) with

Mr. Rana Gurtej Singh, Jr. Standing Counsel and

Ms. Muskaan Gupta, Advocate

for respondent-Income Tax Department

*** JAGMOHAN BANSAL, J. (ORAL)

The appellant through instant appeal under Section 260A of Income Tax Act, 1961 (for short ‘1961 Act’) is seeking setting aside of order dated 16.05.2012 passed by Income Tax Appellate Tribunal, Chandigarh Bench, Chandigarh (for short ‘Tribunal’) for the Assessment Year 2009-10. 2.

Learned counsel for the parties are ad idem that three issues are involved namely (i) Disallowance under Section 14(A) on the securities held in stock; (ii) Applicability of Section 41(4) read with 36(1)(vii) with respect to recovery of bad debts which were written off in the earlier assessment years, however, deduction was never claimed; and (iii) Disallowance of DEEPAK BISSYAN 2025.12.22 10:07 I attest to the accuracy and integrity of this document

ITA-200-2012

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unclaimed balance in Nostro-Blocked account. 3.

They further concede that matter may be remanded to Tribunal to pass fresh order, in the light of orders passed by Hon’ble Supreme Court as well as Tribunal itself after passing of impugned order. 4.

In the wake of statement of both sides, the impugned order is hereby set aside and matter is remanded back to Tribunal for passing fresh order in accordance with law. 5.

Disposed of in above terms. 6.

Pending application(s), if any, stands disposed of.

(JAGMOHAN BANSAL)

JUDGE

(AMARINDER SINGH GREWAL)

JUDGE December 19, 2025 Deepak DPA

Whether Speaking/reasoned Yes/No

Whether Reportable

Yes/No DEEPAK BISSYAN 2025.12.22 10:07 I attest to the accuracy and integrity of this document